- 3 - Background James G. and Katherine Bourekis (petitioners) claimed a loss on their 1981 Federal income tax return related to their investment in PCS Ltd. Partnership (PCS or the partnership). Following an examination of the partnership, respondent proposed to disallow a substantial portion of petitioners' claimed loss. As a consequence of these developments, petitioners (1) agreed to extend the period of limitations for their 1981 tax year and (2) agreed to be bound by the Court's redetermination of the PCS loss issue in Kantor v. Commissioner, T.C. Memo. 1990-380, affd. in part and revd. in part 998 F.2d 1514 (9th Cir. 1993). In June 1996, petitioners received a letter from Revenue Agent Janet Kenley, along with a copy of the opinion issued by the Court of Appeals for the Ninth Circuit in Kantor, a Form 4549 (an examination report), and a Form 870 (a closing agreement). In the letter, Revenue Agent Kenley advised petitioners that a final decision had been entered in the Kantor case sustaining respondent's determination disallowing the PCS loss. The Form 4549, which contained a computation of petitioners' 1981 tax liability including the disallowance of petitioners' distributive share of the PCS loss, indicated that petitioners are liable for a deficiency in tax in the amount of $4,472, as well as statutory interest on the deficiency computed through June 30, 1996, in the amount of $15,174. Revenue Agent Kenley's letter, which alsoPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011